T.C. Memo UNITED STATES TAX COURT. MICHAEL NEIL MCWHORTER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
|
|
- Stella Douglas
- 5 years ago
- Views:
Transcription
1 T.C. Memo UNITED STATES TAX COURT MICHAEL NEIL MCWHORTER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No Filed November 24, Michael Neil McWhorter, pro se. John P. Stemwedel, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION COHEN, Judge: Respondent determined a deficiency of $44,941 in petitioner s Federal income tax for 2002 and additions to tax under sections 6651(a)(1) and (2) and 6654(a). After concessions, the issues for decision are whether petitioner performed services as an employee and whether he is liable for the additions to tax. Unless otherwise indicated, all section
2 - 2 - references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. Petitioner resided in Texas at the time that he filed his petition. During 2002 he resided in Arizona. Commencing in 2001 and ending in 2004, petitioner performed services as a project manager for Boyle Energy Services and Technology, Inc. (Boyle Energy). Boyle Energy hired petitioner because of his knowledge of power plants and specialized knowledge and expertise in industrial pipe fitting. His work for Boyle Energy focused on industrial cleaning of steam piping in power plants as part of the process of recommissioning the plants. Petitioner received no training from Boyle Energy regarding either its procedures or on industrial pipe fitting. Petitioner s training by Boyle Energy was restricted to teaching him the recommissioning process of the company. Petitioner s work for Boyle Energy was on a project-byproject basis. He had authority to supervise the personnel of Boyle Energy and of client companies. Petitioner did not have any hiring or firing authority over Boyle Energy personnel and had to contact Boyle Energy before removing its personnel from a
3 - 3 - job site. Petitioner had a credit card with the name of Boyle Energy on it and a business card with the company logo on it. Petitioner invoiced Boyle Energy for services rendered per project. The invoices and the subsequent payments were at a rate of $500 per day for petitioner s labor during Petitioner did not provide Boyle Energy with timesheets. Boyle Energy paid the amount shown on petitioner s invoices and issued to petitioner a Form 1099-MISC, Miscellaneous Income, for 2002, reporting $126,760 as nonemployee compensation. Petitioner received a Form 1099 from Boyle Energy for each of the years 2001, 2002, 2003, and He never received a Form W-2, Wage and Tax Statement, from Boyle Energy. Petitioner failed to file a Federal income tax return for For that year he received compensation of $126,760 from Boyle Energy, $ of short-term capital gain, and $2 of interest income. No Federal income tax was withheld from any of the amounts that petitioner received, and he failed to make any payments of estimated taxes during The Internal Revenue Service (IRS) prepared a substitute for return under section 6020(b) with respect to petitioner s Federal income tax liability. In the notice of deficiency, the IRS determined that petitioner was liable for self-employment tax on the income received from Boyle Energy.
4 - 4 - OPINION Petitioner claims that he was an employee of Boyle Energy and not an independent contractor liable for self-employment taxes. He initially claimed that Boyle Energy should be responsible for the income taxes that were not withheld. By the conclusion of the trial, however, he understood that the issues remaining in dispute were his liability for self-employment tax and the additions to tax for failure to file a tax return, failure to pay tax due on a return, and failure to make estimated tax payments. Respondent contends that petitioner is liable for selfemployment tax under sections 1401(a) and Respondent argues that petitioner was not an employee under the definition set out in section 3121(d). See sec (c)-3(a), Income Tax Regs. Respondent relies on the test set out in Breaux & Daigle, Inc. v. United States, 900 F.2d 49, 51 (5th Cir. 1990) (citing United States v. Silk, 331 U.S. 704, 716 (1947)), and the following factors: (1) Degree of control, (2) opportunities for profit or loss, (3) investment in facilities, (4) permanency of relation, and (5) skill required in the operation in question. The list is not exclusive, and no one factor is controlling. Id. Respondent argues that the degree of control by Boyle Energy, the lack of permanency in the relationship, and the skill required in petitioner s work supports respondent s contention
5 - 5 - that petitioner was an independent contractor during Respondent concedes that the lack of opportunities for profit or investment in the facilities supports petitioner s contention that he was an employee. Recognizing that this is a close case, respondent argues that the understanding of the parties to the contract should be given weight. See McCormick v. United States, 209 Ct. Cl. 331, 531 F.2d 554, 560 (1976); Herman v. Commissioner, T.C. Memo ; Steffens v. Commissioner, T.C. Memo ; Bothke v. Commissioner, T.C. Memo ; Springfield Prods., Inc. v. Commissioner, T.C. Memo ; Harris v. Commissioner, T.C. Memo Respondent asserts: Petitioner contends that there was an ongoing dispute with Boyle Energy regarding his status. Petitioner acknowledges, however, that he worked under this arrangement from 2001 until he ended the relationship in 2004 for unrelated reasons. If there was a valid dispute as to his status, petitioner essentially acquiesced to Boyle Energy s understanding of his status by continuing to work under this arrangement. And despite the availability of persons aware of his employment status and relationship with Boyle Engineering [sic] over the period in question, such as Mike Boyle and Diane Gagnon, petitioner did not obtain any evidence to corroborate his testimony where it is at variance with documentary evidence. Of course, respondent also could have called witnesses concerning the nature of the relationship between petitioner and Boyle Energy. Because petitioner s testimony was credible with respect
6 - 6 - to his arrangements with Boyle Energy, the absence of corroborating evidence is not determinative. Cf. Boyd v. Commissioner, 122 T.C. 305, 320 (2004). Petitioner s acquiescence in Boyle Energy s treatment of him as an independent contractor for tax purposes is troubling. As discussed below, he has presented no reasonable excuse for his failure to file a return and pay the income tax due. On the limited record that we have, however, we conclude that petitioner was an employee of Boyle Energy during 2002 and should have been treated as such for tax purposes. In respondent s pretrial memorandum, respondent referred to section 7491(a) and asserted that petitioner had failed to produce any evidence that he was an employee and not an independent contractor of Boyle Energy. At trial, however, the nature of petitioner s employment was the subject of his testimony, and his testimony was credible. In the posttrial brief, respondent does not challenge the credibility of petitioner s testimony and acknowledges that some of the relevant factors favor petitioner. Respondent does not address section 7491(a)(1) in the posttrial brief. Thus respondent does not claim that any of the limitations in section 7491(a)(2) prevent application of the general rule that: SEC BURDEN OF PROOF. (a) Burden Shifts Where Taxpayer Produces Credible Evidence.--
7 - 7 - (1) General rule.--if, in any court proceeding, a taxpayer introduces credible evidence with respect to any factual issue relevant to ascertaining the liability of the taxpayer for any tax imposed by subtitle A or B, the Secretary shall have the burden of proof with respect to such issue. We conclude that the burden of proof in this case shifted to respondent. We are not persuaded that the factors relied on by respondent prove that petitioner was an independent contractor with respect to the services that he performed for Boyle Energy. Neither the degree of control exercised by Boyle Energy nor the amount of skill possessed by petitioner distinguishes his situation from that of a supervisory employee. We are not persuaded that a job that continued from 2001 into 2004 can be described as impermanent. Respondent acknowledges that other factors favor petitioner. On the record that has been made, we conclude that respondent did not carry the burden of proof. Petitioner is not liable for self-employment tax for Respondent also had the burden of production with respect to the additions to tax under sections 6651(a) and See sec. 7491(c). Petitioner stipulated that he failed to file a return for 2002 and that a substitute tax return was prepared under section 6020(b). Respondent introduced evidence that petitioner also failed to file a return for 2001.
8 - 8 - Section 6651(a) imposes additions to tax for failure to file a return and failure to pay the amount shown as tax on a return. Petitioner s only explanation of his failure to file a return for 2002 is that he did not want to sign a return saying that he was an independent contractor. He has no reasonable cause, however, for failing to file a return reporting that he received $126,760 in compensation and other amounts of income during The failure of Boyle Energy to withhold taxes that should have been withheld neither excuses petitioner s failure to file the return and pay the taxes nor relieves him of the additions to tax under section 6651(a). See Escandon v. Commissioner, T.C. Memo ; Lucas v. Commissioner, T.C. Memo Section 6654 imposes an addition to tax when a taxpayer fails to make a required installment of estimated income tax. Each required installment is equal to 25 percent of the required annual payment. Sec. 6654(d)(1)(A). The required annual payment is the lesser of (1) 90 percent of the tax shown on the return for the taxable year (or, if the taxpayer filed no return, 90 percent of the tax for that year), or (2) 100 percent of the tax shown on the return for the preceding taxable year. Sec. 6654(d)(1)(B). Because petitioner failed to file a return for 2001, his required annual payment for 2002 was 90 percent of the
9 - 9 - tax for that year. Because petitioner failed to pay any Federal income tax for 2002, the section 6654 addition to tax applies to the recomputed deficiency. The implication of our holding that petitioner was an employee of Boyle Energy for 2002 is that he may be liable for his share of taxes under the Federal Insurance Contributions Act, section 3101(a) and (b). That determination, however, is not within our jurisdiction in this case. See Lucas v. Commissioner, supra n.3; Grooms v. Commissioner, T.C. Memo To reflect the foregoing, Decision will be entered under Rule 155.
T.C. Memo UNITED STATES TAX COURT. JOHN KELLER, ACTION AUTO BODY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2012-62 UNITED STATES TAX COURT JOHN KELLER, ACTION AUTO BODY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 28991-09. Filed March 8, 2012. R determined that 10 of P
More informationT.C. Memo UNITED STATES TAX COURT
T.C. Memo. 2012-6 UNITED STATES TAX COURT ESTATE OF DWIGHT T. FUJISHIMA, DECEASED, EVELYN FUJISHIMA, PERSONAL ADMINISTRATOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3930-10.
More informationT.C. Memo United States Tax Court. JOHN A. AND MARY L. BATOK v. COMMISSIONER. Docket No Filed December 28, 1992.
T.C. Memo 1992-727 United States Tax Court JOHN A. AND MARY L. BATOK v. COMMISSIONER. Docket No. 18571-91. Filed December 28, 1992. John A. Batok, pro se. Dale Raymond, for the respondent. MEMORANDUM OPINION
More informationT.C. Memo UNITED STATES TAX COURT. RAMESH T. KUMAR AND PUSHPARANI V. KUMAR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2013-184 UNITED STATES TAX COURT RAMESH T. KUMAR AND PUSHPARANI V. KUMAR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4334-08. Filed August 13, 2013. Richard Harry
More informationT.C. Summary Opinion UNITED STATES TAX COURT. LUCAS MATTHEW MCCARVILLE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Summary Opinion 2016-14 UNITED STATES TAX COURT LUCAS MATTHEW MCCARVILLE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 22267-14S. Filed April 4, 2016. Lucas Matthew McCarville,
More informationT.C. Memo UNITED STATES TAX COURT. CENTRAL MOTORPLEX, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2014-207 UNITED STATES TAX COURT CENTRAL MOTORPLEX, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19754-11. Filed October 7, 2014. William G. Coleman, Jr., for
More informationHowell v. Commissioner TC Memo
CLICK HERE to return to the home page Howell v. Commissioner TC Memo 2012-303 MARVEL, Judge MEMORANDUM FINDINGS OF FACT AND OPINION Respondent mailed to petitioners a notice of deficiency dated December
More informationT.C. Memo UNITED STATES TAX COURT. KENNETH L. MALLORY AND LARITA K. MALLORY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2016-110 UNITED STATES TAX COURT KENNETH L. MALLORY AND LARITA K. MALLORY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14873-14. Filed June 6, 2016. Joseph A. Flores,
More informationT.C. Memo UNITED STATES TAX COURT
T.C. Memo. 2014-100 UNITED STATES TAX COURT ESTATE OF HAZEL F. HICKS SANDERS, DECEASED, MICHAEL W. SANDERS AND SALLIE S. WILLIAMSON, CO-EXECUTORS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
More informationT.C. Memo UNITED STATES TAX COURT. ERNEST N. ZWEIFEL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2012-93 UNITED STATES TAX COURT ERNEST N. ZWEIFEL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent CREWS ALL NITE BAIL BONDS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE,
More informationT.C. Memo UNITED STATES TAX COURT. ORALIA PAVIA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2008-270 UNITED STATES TAX COURT ORALIA PAVIA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 640-07. Filed December 4, 2008. Oralia Pavia, pro se. Jeffrey D. Heiderscheit,
More informationT.C. Memo UNITED STATES TAX COURT. NICHOLAS A. AND MARJORIE E. PALEVEDA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 1997-416 UNITED STATES TAX COURT NICHOLAS A. AND MARJORIE E. PALEVEDA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 840-96. Filed September 18, 1997. Nicholas A. Paleveda,
More informationT.C. Memo UNITED STATES TAX COURT. MATTI KOSONEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2000-107 UNITED STATES TAX COURT MATTI KOSONEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4259-98. Filed March 28, 2000. Andrew I. Panken and Robert A. DeVellis,
More informationT.C. Memo UNITED STATES TAX COURT. YULIA FEDER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2012-10 UNITED STATES TAX COURT YULIA FEDER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1628-10. Filed January 10, 2012. Frank Agostino, Lawrence M. Brody, and Jeffrey
More informationT.C. Memo UNITED STATES TAX COURT. EDWARD S. FLUME, Petitioner v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent
T.C. Memo. 2017-21 UNITED STATES TAX COURT EDWARD S. FLUME, Petitioner v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Respondent Docket No. 15772-14L. Filed January 30, 2017. David Rodriguez, for petitioner.
More informationT.C. Summary Opinion UNITED STATES TAX COURT
T.C. Summary Opinion 2016-57 UNITED STATES TAX COURT MARIO JOSEPH COLLODI, JR. AND ELIZABETH LOUISE COLLODI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 17131-14S. Filed September
More informationYulia Feder v. Commissioner, TC Memo , Code Sec(s) 61; 72; 6201; 7491.
Checkpoint Contents Federal Library Federal Source Materials Federal Tax Decisions Tax Court Memorandum Decisions Tax Court Memorandum Decisions (Current Year) Advance Tax Court Memorandums Yulia Feder,
More information119 T.C. No. 5 UNITED STATES TAX COURT. JOSEPH M. GREY PUBLIC ACCOUNTANT, P.C., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
119 T.C. No. 5 UNITED STATES TAX COURT JOSEPH M. GREY PUBLIC ACCOUNTANT, P.C., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4789-00. Filed September 16, 2002. This is an action
More informationThis case is referenced in an endnote at the Bradford Tax Institute. CLICK HERE to go to the home page.
This case is referenced in an endnote at the Bradford Tax Institute. CLICK HERE to go to the home page. 123 T.C. No. 16 UNITED STATES TAX COURT TONY R. CARLOS AND JUDITH D. CARLOS, Petitioners v. COMMISSIONER
More informationPURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE.
PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE. T.C. Summary Opinion 2009-94 UNITED STATES TAX COURT RAMON EMILIO PEREZ, Petitioner v.
More informationThis case is referenced in an endnote at the Bradford Tax Institute. CLICK HERE to go to the home page. T.C. Memo UNITED STATES TAX COURT
This case is referenced in an endnote at the Bradford Tax Institute. CLICK HERE to go to the home page. T.C. Memo. 2004-132 UNITED STATES TAX COURT FRANK CHEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE,
More informationBURDEN OF PROOF. Shift Happens
BURDEN OF PROOF Shift Happens Overview of Presentation 1. Information Returns 2. Issue Specific 3. Statutory - 7491 4. General Production v. Persuasion Burden of going forward Reasonable person can find
More informationT.C. Memo UNITED STATES TAX COURT. ALEX AND TONJA ORIA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2007-226 UNITED STATES TAX COURT ALEX AND TONJA ORIA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 246-05. Filed August 14, 2007. Steve M. Williard, for petitioners.
More informationT.C. Memo UNITED STATES TAX COURT. STEVEN A. SODIPO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2015-3 UNITED STATES TAX COURT STEVEN A. SODIPO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19156-12. Filed January 5, 2015. Steven A. Sodipo, pro se. William J. Gregg,
More informationThis case is referenced in an endnote at the Bradford Tax Institute. CLICK HERE to go to the home page.
This case is referenced in an endnote at the Bradford Tax Institute. CLICK HERE to go to the home page. T.C. Memo. 1998-23 UNITED STATES TAX COURT PAUL M. AND JUNE S. SENGPIEHL, Petitioners v. COMMISSIONER
More informationT.C. Memo UNITED STATES TAX COURT. CHRISTINE C. PETERSON AND ROGER V. PETERSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2013-271 UNITED STATES TAX COURT CHRISTINE C. PETERSON AND ROGER V. PETERSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 16263-11, 2068-12. Filed November 25, 2013.
More information142 T.C. No. 4 UNITED STATES TAX COURT. LAW OFFICE OF JOHN H. EGGERTSEN P.C., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
142 T.C. No. 4 UNITED STATES TAX COURT LAW OFFICE OF JOHN H. EGGERTSEN P.C., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15479-11. Filed February 12, 2014. During its taxable
More informationLind v. Commissioner T.C. Memo
CLICK HERE to return to the home page Lind v. Commissioner T.C. Memo 1985-490 Memorandum Opinion PARKER, Judge: Respondent determined a deficiency in petitioners' 1980 Federal income tax in the amount
More informationT.C. Memo UNITED STATES TAX COURT. ROBERT LIPPOLIS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2017-104 UNITED STATES TAX COURT ROBERT LIPPOLIS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18172-12W. Filed June 7, 2017. Thomas C. Pliske, for petitioner. Ashley
More informationT.C. Memo UNITED STATES TAX COURT. MARK ROBERT OHDE AND ROSE M. OHDE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2017-137 UNITED STATES TAX COURT MARK ROBERT OHDE AND ROSE M. OHDE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11688-15. Filed July 10, 2017. Floyd M. Sayre, III,
More informationv. Docket 'No S
UNITED STATES TAX COURT Washington, D.C. 20217 GERNOT AND HELGA RUTH MUELLER, Petitioners, v. Docket 'No. 532-89S COMMISSIONER OF INTERNAL REVENUE, Respondent. DECISION Pursuant to the determination of
More informationPURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE.
PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE. T.C. Summary Opinion 2002-150 UNITED STATES TAX COURT KARL AND BIRGIT JAHINA, Petitioners
More informationT.C. Memo UNITED STATES TAX COURT. CHARLES D. SHAFFRAN, SR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2017-35 UNITED STATES TAX COURT CHARLES D. SHAFFRAN, SR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12611-12L. February 16, 2017. Charles D. Shaffran, Sr., pro se.
More information143 T.C. No. 5 UNITED STATES TAX COURT. PARIMAL H. SHANKAR AND MALTI S. TRIVEDI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
143 T.C. No. 5 UNITED STATES TAX COURT PARIMAL H. SHANKAR AND MALTI S. TRIVEDI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 24414-12. Filed August 26, 2014. R disallowed Ps'
More informationThis case is referenced in an endnote at the Bradford Tax Institute. CLICK HERE to go to the home page. T.C. Memo UNITED STATES TAX COURT
This case is referenced in an endnote at the Bradford Tax Institute. CLICK HERE to go to the home page. T.C. Memo. 2007-351 UNITED STATES TAX COURT RALPH E. FRAHM & ERIKA C. FRAHM, Petitioners v. COMMISSIONER
More informationT.C. Memo UNITED STATES TAX COURT. WEST COVINA MOTORS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2008-237 UNITED STATES TAX COURT WEST COVINA MOTORS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4802-04. Filed October 27, 2008. Steven Ray Mather, for petitioner.
More informationT.C. Memo UNITED STATES TAX COURT. EUGENE W. ALPERN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2000-246 UNITED STATES TAX COURT EUGENE W. ALPERN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20304-98. Filed August 8, 2000. Eugene W. Alpern, pro se. Gregory J.
More informationPURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE.
PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE. T.C. Summary Opinion 2013-62 UNITED STATES TAX COURT SEAN MCALARY LTD, INC., Petitioner
More informationThis case is referenced in an endnote at the Bradford Tax Institute. CLICK HERE to go to the home page. T.C. Memo UNITED STATES TAX COURT
This case is referenced in an endnote at the Bradford Tax Institute. CLICK HERE to go to the home page. T.C. Memo. 2006-261 UNITED STATES TAX COURT FRANK M. SETTIMO AND SALLYN M. SETTIMO, Petitioners v.
More informationMoretti v. Commissioner T.C. Memo (T.C. 1982)
CLICK HERE to return to the home page Moretti v. Commissioner T.C. Memo 1982-552 (T.C. 1982) Gene Moretti, pro se. Barbara A. Matthews, for the respondent. Memorandum Findings of Fact and Opinion NIMS,
More informationIN THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT
Peter McLauchlan v. Case: CIR 12-60657 Document: 00512551524 Page: 1 Date Filed: 03/06/2014Doc. 502551524 IN THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT PETER A. MCLAUCHLAN, United States
More informationT.C. Memo UNITED STATES TAX COURT. L.A. AND RAYANI SAMARASINGHE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
This Tax Court Memo is referenced in an endnote at the Bradford Tax Institute. CLICK HERE to go to the home page. T.C. Memo. 2012-23 UNITED STATES TAX COURT L.A. AND RAYANI SAMARASINGHE, Petitioners v.
More informationPURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE.
PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE. T.C. Summary Opinion 2010-127 UNITED STATES TAX COURT SVEND F. AND MISCHELLE T. STENSLET,
More information138 T.C. No. 22 UNITED STATES TAX COURT. JACK TRUGMAN AND JOAN E. TRUGMAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
This opinion is referenced in an endnote at the Bradford Tax Institute. CLICK HERE to go to the home page. 138 T.C. No. 22 UNITED STATES TAX COURT JACK TRUGMAN AND JOAN E. TRUGMAN, Petitioners v. COMMISSIONER
More informationBobrow v. Comm'r T.C. Memo (T.C. 2014)
CLICK HERE to return to the home page Bobrow v. Comm'r T.C. Memo 2014-21 (T.C. 2014) MEMORANDUM OPINION NEGA, Judge: Respondent determined a deficiency in petitioners' income tax for taxable year 2008
More information140 T.C. No. 8 UNITED STATES TAX COURT
140 T.C. No. 8 UNITED STATES TAX COURT WISE GUYS HOLDINGS, LLC, PETER J. FORSTER, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6643-12. Filed April 22, 2013.
More information136 T.C. No. 29 UNITED STATES TAX COURT. STEPHEN G. WOODSUM AND ANNE R. LOVETT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
136 T.C. No. 29 UNITED STATES TAX COURT STEPHEN G. WOODSUM AND ANNE R. LOVETT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18934-09. Filed June 13, 2011. In 2006 Ps received
More informationThis case is referenced in an endnote at the Bradford Tax Institute. CLICK HERE to go to the home page. UNITED STATES TAX COURT
This case is referenced in an endnote at the Bradford Tax Institute. CLICK HERE to go to the home page. T.C. Memo. 2010-262 UNITED STATES TAX COURT HAL HOLLINGSWORTH, Petitioner v. COMMISSIONER OF INTERNAL
More informationTibor I. Szkircsak v. Commissioner TC Memo
CLICK HERE to return to the home page Tibor I. Szkircsak v. Commissioner TC Memo 1980-129 MEMORANDUM FINDINGS OF FACT AND OPINION DRENNEN, Judge: Respondent determined a deficiency of $2,884.57 in petitioners'
More informationsus PETITIONERS' SUPPLEMENTAL BRIEF MAY * MAY US TAX COURT gges t US TAX COURT 7:32 PM LAWRENCE G. GRAEV & LORNA GRAEV, Petitioners,
US TAX COURT gges t US TAX COURT RECEIVED y % sus efiled MAY 31 2017 * MAY 31 2017 7:32 PM LAWRENCE G. GRAEV & LORNA GRAEV, Petitioners, ELECTRONICALLY FILED v. Docket No. 30638-08 COMMISSIONER OF INTERNAL
More informationPURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE.
PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE. T.C. Summary Opinion 2014-68 UNITED STATES TAX COURT PATRICIA DIANE ROSS, Petitioner v.
More informationPURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE.
PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE. T.C. Summary Opinion 2012-94 UNITED STATES TAX COURT STEPHEN A. WALLACH AND KIMBERLY K.
More informationT.C. Summary Opinion UNITED STATES TAX COURT
T.C. Summary Opinion 2016-19 UNITED STATES TAX COURT WENDELL WILSON AND ANGELICA M. WILSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 16610-13S. Filed April 25, 2016. Wendell
More informationFrederick R. Mayer and Jan Perry Mayer v. Commissioner.
Frederick R. Mayer and Jan Perry Mayer v. Commissioner., United States Tax Court - Memorandum Decision, T.C. Memo. 1994-209, Docket No. 12927-91., Filed May 11, 1994 25.06.2008 Frederick R. Mayer and Jan
More informationRugby Productions Ltd. v. Commissioner 100 T.C. 531 (T.C. 1993)
Rugby Productions Ltd. v. Commissioner 100 T.C. 531 (T.C. 1993) CLICK HERE to return to the home page Alan G. Kirios and David J. Gullen, for petitioner. Marilyn Devin, for respondent. OPINION NIMS, Judge:
More informationVan Camp & Bennion v. United States 251 F.3d 862 (9th Cir. Wash. 2001).
Van Camp & Bennion v. United States 251 F.3d 862 (9th Cir. Wash. 2001). CLICK HERE to return to the home page No. 96-36068. United States Court of Appeals, Ninth Circuit. Argued and Submitted September
More informationADMINISTRATIVE DECISION
STATE OF ARKANSAS DEPARTMENT OF FINANCE AND ADMINISTRATION OFFICE OF HEARINGS & APPEALS ADMINISTRATIVE DECISION IN THE MATTER OF (ACCT. NO.: ) INDIVIDUAL INCOME TAX ASSESSMENT DOCKET NO.: 17-061 TAX YEAR
More informationT.C. Memo UNITED STATES TAX COURT. RAYMOND S. MCGAUGH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2016-28 UNITED STATES TAX COURT RAYMOND S. MCGAUGH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13665-14. Filed February 24, 2016. P had a self-directed IRA of which
More informationBartlett v. Comm'r T.C. Memo (T.C. 2013)
CLICK HERE to return to the home page Bartlett v. Comm'r T.C. Memo 2013-182 (T.C. 2013) MEMORANDUM FINDINGS OF FACT AND OPINION KERRIGAN, Judge: Respondent determined the following deficiencies and penalties
More informationCedric R. Kotowicz TC Memo
Cedric R. Kotowicz TC Memo 1991-563 CLICK HERE to return to the home page GOFFE, Judge: The Commissioner determined the following deficiencies in income tax and additions to tax against petitioner: Taxable
More informationT.C. Memo UNITED STATES TAX COURT. JANUARY TRANSPORT, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2008-268 UNITED STATES TAX COURT JANUARY TRANSPORT, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14484-06. Filed December 3, 2008. Jon H. Trudgeon, for petitioner.
More informationPURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE.
PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE. T.C. Summary Opinion 2012-12 UNITED STATES TAX COURT ANDREA READY, Petitioner v. COMMISSIONER
More informationWilliams v Commissioner TC Memo
CLICK HERE to return to the home page Williams v Commissioner TC Memo 2015-76 Respondent determined deficiencies in petitioners' income tax for tax years 2009 and 2010 of $8,712 and $17,610, respectively.
More informationFeistman v. Commissioner T.C. Memo (T.C. 1982).
CLICK HERE to return to the home page Feistman v. Commissioner T.C. Memo 1982-306 (T.C. 1982). Memorandum Findings of Fact and Opinion RAUM, Judge: The Commissioner determined income tax deficiencies of
More informationLapinel v. Commissioner T.C. Memo (T.C. 1989)
CLICK HERE to return to the home page Lapinel v. Commissioner T.C. Memo 1989-685 (T.C. 1989) MEMORANDUM FINDINGS OF FACT AND OPINION NIMS, Chief Judge: Respondent determined the following deficiency in
More informationS & H, Inc. v. Commissioner 78 T.C. 234 (T.C. 1982)
CLICK HERE to return to the home page S & H, Inc. v. Commissioner 78 T.C. 234 (T.C. 1982) Thomas A. Daily, for the petitioner. Juandell D. Glass, for the respondent. DRENNEN, Judge: Respondent determined
More informationT.C. Memo UNITED STATES TAX COURT. PAMELA LYNN BROOKS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2013-141 UNITED STATES TAX COURT PAMELA LYNN BROOKS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9544-11. Filed June 4, 2013. Pamela Lynn Brooks, pro se. Donald D.
More informationT.C. Memo UNITED STATES TAX COURT. MURRAY S. FRIEDLAND, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2011-90 UNITED STATES TAX COURT MURRAY S. FRIEDLAND, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13926-10W. Filed April 25, 2011. Murray S. Friedland, pro se. John
More informationT.C. Memo UNITED STATES TAX COURT. JAMES MAGUIRE AND JOY MAGUIRE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2012-160 UNITED STATES TAX COURT JAMES MAGUIRE AND JOY MAGUIRE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent MARC MAGUIRE AND PAMELA MAGUIRE, Petitioners v. COMMISSIONER OF INTERNAL
More information141 T.C. No. 19 UNITED STATES TAX COURT. ANDREW WAYNE ROBERTS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
141 T.C. No. 19 UNITED STATES TAX COURT ANDREW WAYNE ROBERTS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23405-10. Filed December 30, 2013. During 2008 P s former wife (W) submitted
More informationT.C. Memo UNITED STATES TAX COURT. JASON R. BECK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2015-149 UNITED STATES TAX COURT JASON R. BECK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 25842-10. Filed August 10, 2015. Jason R. Beck, pro se. Carolyn A. Schenck
More information680 REALTY PARTNERS AND CRC REALTY CAPITAL CORP. - DECISION - 04/26/96
680 REALTY PARTNERS AND CRC REALTY CAPITAL CORP. - DECISION - 04/26/96 In the Matter of 680 REALTY PARTNERS AND CRC REALTY CAPITAL CORP. TAT (E) 93-256 (UB) - DECISION TAT (E) 95-33 (UB) NEW YORK CITY
More information137 T.C. No. 4 UNITED STATES TAX COURT. KENNETH WILLIAM KASPER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
137 T.C. No. 4 UNITED STATES TAX COURT KENNETH WILLIAM KASPER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13399-10W. Filed July 12, 2011. On Jan. 29, 2009, P filed with R a claim
More informationCox v. Commissioner T.C. Memo (T.C. 1993)
CLICK HERE to return to the home page Cox v. Commissioner T.C. Memo 1993-326 (T.C. 1993) MEMORANDUM OPINION BUCKLEY, Special Trial Judge: This matter is assigned pursuant to the provisions of section 7443A(b)(3)
More informationThis case is referenced in an endnote at the Bradford Tax Institute. CLICK HERE to go to the home page. 114 T.C. No. 14 UNITED STATES TAX COURT
This case is referenced in an endnote at the Bradford Tax Institute. CLICK HERE to go to the home page. 114 T.C. No. 14 UNITED STATES TAX COURT SUTHERLAND LUMBER-SOUTHWEST, INC., Petitioner v. COMMISSIONER
More informationFisher v. Commissioner 54 T.C. 905 (T.C. 1970)
CLICK HERE to return to the home page Fisher v. Commissioner 54 T.C. 905 (T.C. 1970) United States Tax Court. Filed April 29, 1970. Maurice Weinstein, for the petitioners. Denis J. Conlon, for the respondent.
More informationGAW v. COMMISSIONER 70 T.C.M. 336 (1995) T.C. Memo Docket No United States Tax Court. Filed August 8, MEMORANDUM OPINION
1 of 6 06-Oct-2012 18:01 GAW v. COMMISSIONER 70 T.C.M. 336 (1995) T.C. Memo. 1995-373 Anthony Teong-Chan Gaw and Rosanna W. Gaw v. Commissioner. Docket No. 8015-92. United States Tax Court. Filed August
More informationLEONARD I. HOROWITZ - DETERMINATION - 09/15/04. In the Matter of LEONARD I. HOROWITZ TAT(H) 99-3(UB) ET AL. - DETERMINATION
LEONARD I. HOROWITZ - DETERMINATION - 09/15/04 In the Matter of LEONARD I. HOROWITZ TAT(H) 99-3(UB) ET AL. - DETERMINATION NEW YORK CITY TAX APPEALS TRIBUNAL ADMINISTRATIVE LAW JUDGE DIVISION UNINCORPORATED
More informationTschetschot v. Comm'r T.C. Memo (T.C. 2007)
CLICK HERE to return to the home page Tschetschot v. Comm'r T.C. Memo 2007-38 (T.C. 2007) MEMORANDUM FINDINGS OF FACT AND OPINION ARMEN, Special Trial Judge: Respondent determined a deficiency in petitioners'
More informationT.C. Memo UNITED STATES TAX COURT. RUBEN DE LOS SANTOS AND MARTHA DE LOS SANTOS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2018-155 UNITED STATES TAX COURT RUBEN DE LOS SANTOS AND MARTHA DE LOS SANTOS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5458-16. Filed September 18, 2018. respondent.
More informationProvided Courtesy of:
Provided Courtesy of: Banister Financial, Inc. 1338 Harding Place, Suite 200 Charlotte, NC 28204 Phone (Main): 704-334-4932 Fax: 704-334-5770 www.businessvalue.com For information, contact: George B. Hawkins,
More informationUS TAX COURT gges t US TAX COURT JUL * JUL :39 AM. v. Docket No
US TAX COURT gges t US TAX COURT RECEIVED y % sus efiled JUL 19 2018 * JUL 19 2018 12:39 AM RESERVE MECHANICAL CORP. F.K.A. RESERVE CASUALTY CORP., Petitioner, ELECTRONICALLY FILED v. Docket No. 14545-16
More informationTaxpayer Testimony as Credible Evidence
Author: Raby, Burgess J.W.; Raby, William L., Tax Analysts Taxpayer Testimony as Credible Evidence When section 7491, which shifts the burden of proof to the IRS for some taxpayers, was added to the tax
More informationCLICK HERE to return to the home page
CLICK HERE to return to the home page JOHN B. RESLER AND SANDRA RESLER, ROSEANNE R. NEWMAN, ROBERT ARONSON AND JOAN ARONSON, CHRISTINE B. ARONSON, JANE E. ARONSON, ANDREW D. ARONSON, Petitioners v. COMMISSIONER
More informationRussell v Commissioner TC Memo
CLICK HERE to return to the home page Russell v Commissioner TC Memo 1994-96 This case was heard pursuant to the provisions of section 7443A(b)(3) 1 and Rules 180, 181, and 182. Respondent determined deficiencies
More informationSandoval v. Commissioner T.C. Memo (T.C. 2000)
CLICK HERE to return to the home page Sandoval v. Commissioner T.C. Memo 2000-189 (T.C. 2000) MEMORANDUM FINDINGS OF FACT AND OPINION COLVIN, JUDGE: Respondent determined deficiencies in petitioners' Federal
More information136 T.C. No. 30 UNITED STATES TAX COURT. WILLIAM PRENTICE COOPER, III, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
136 T.C. No. 30 UNITED STATES TAX COURT WILLIAM PRENTICE COOPER, III, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 24178-09W, 24179-09W. Filed June 20, 2011. P filed two claims
More informationThis case is referenced in an endnote at the Bradford Tax Institute. CLICK HERE to go to the home page. T.C. Memo UNITED STATES TAX COURT
This case is referenced in an endnote at the Bradford Tax Institute. CLICK HERE to go to the home page. T.C. Memo. 2011-219 UNITED STATES TAX COURT TOM AND NANCY MILLER, Petitioners v. COMMISSIONER OF
More informationEditor's Summary. Facts. District Court [opinion at p. 686] Court of Appeals [opinion below]
CARLOATE INDUSTRIES INC. v. UNITED STATES 354 F.2d 814; 66-1 USTC 9159; 17 AFTR 2{1 59 (5th Cir. 1966). Reversing 230 F. Supp. 282; 64-2 USTC 9564; 14 AFTR 2d 5327 (S.D. Tex. 1964). Key Topics CASUALTY
More informationT.C. Memo UNITED STATES TAX COURT
T.C. Memo. 2017-127 UNITED STATES TAX COURT ELLIS J. SALLOUM AND MARY VIRGINIA H. SALLOUM, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 17709-15. Filed June 29, 2017. James G.
More informationPURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE.
PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE. T.C. Summary Opinion 2011-44 UNITED STATES TAX COURT KEVIN L. AND LINDA SHERAR, Petitioners
More informationInternational Reciprocal Trade Association Advisory Memo
International Reciprocal Trade Association Advisory Memo IRTA Advisory Memo February 7, 2017 Proper Reporting of Assets and Liabilities of the Managing Exchange vs. the Exchange Members And IRS 1099 Reporting
More informationPage 1 of 7 Coordinated Issue Paper All Industries - State and Local Location Tax Incentives (Effective Date: May 23, 2008) LMSB-04-0408-023 Effective Date: May 23, 2008 STATE
More informationUnited States Court of Appeals
In the United States Court of Appeals No. 02-3262 For the Seventh Circuit WARREN L. BAKER, JR. and DORRIS J. BAKER, v. Petitioners-Appellants, COMMISSIONER OF INTERNAL REVENUE, Appeal from the United States
More informationIN THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT. No
IN THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT No. 01-60978 COMMISSIONER OF INTERNAL REVENUE, versus Petitioner-Appellant, BROOKSHIRE BROTHERS HOLDING, INC. and SUBSIDIARIES, Respondent-Appellee.
More information19 - Taxpayer Had Basis in Solar Panels for Purposes of Bonus Depreciation and Energy Credit
19 - Taxpayer Had Basis in Solar Panels for Purposes of Bonus Depreciation and Energy Credit Golan, TC Memo 2018-76 The Tax Court has concluded that a taxpayer established a basis in solar panels and related
More informationT.C. Memo UNITED STATES TAX COURT. HERB VEST, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2016-187 UNITED STATES TAX COURT HERB VEST, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 15351-13, 15352-13, Filed October 6, 2016. 15353-13. Herb Vest, pro se. Tanya
More informationState of New Jersey OFFICE OF ADMINISTRATIVE LAW
State of New Jersey OFFICE OF ADMINISTRATIVE LAW DECISION OAL DKT. NO. HEA 20864-15 AGENCY DKT. NO. HESAA NEW JERSEY HIGHER EDUCATION STUDENT ASSISTANCE AUTHORITY (NJHESAA; THE AGENCY), Petitioner, v.
More informationBRUCE SELIG AND ELAINE SELIG, Petitioners v. COMMIS-SIONER OF INTERNAL REVENUE, Respondent
CLICK HERE to return to the home page BRUCE SELIG AND ELAINE SELIG, Petitioners v. COMMIS-SIONER OF INTERNAL REVENUE, Respondent T.C. Memo 1995-519 October 31, 1995 MEMORANDUM FINDINGS OF FACT AND OPINION
More informationT.C. Memo UNITED STATES TAX COURT. SECURITAS HOLDINGS, INC. AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
T.C. Memo. 2014-225 UNITED STATES TAX COURT SECURITAS HOLDINGS, INC. AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21206-10. Filed October 29, 2014. petitioner.
More information